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The Metropolitan Police have been criticised for their request to Sue Grey not to prejudice their investigation into parties held at Downing Street during lockdown. Ms Grey has yet to publish her report into the parties, but a “heavily redacted” version is expected “imminently” according to the Guardian. The Met requested the report to make “minimal reference” to the parties, not that it be delayed or otherwise limited, but it has caused some to question the motives and/or competence of the police. It is possible that their investigation will go beyond current public knowledge and if criminal charges result in a jury trial the police do have to ensure potential jurors are not prejudiced. On the other hand, human rights barrister Adam Wagner has questioned why a civil service report on alleged breaches of Covid regulations would prejudice a police investigation.
In other news:
The Equality and Human Rights Commision (EHRC) has come under fire from LGBTQ+ campaigners and Scottish First Minister Nicola Sturgeon for its response to the Scottish government’s plans to simplify the process for legal gender recognition, and the UK government consultation on banning conversion therapy. The EHRC said “more detailed consideration is required before any change is made” to the Gender Recognition Act 2004. Ms Sturgeon noted that this was a “significant change in position” for the EHRC and that she was concerned that the Commission’s response “doesn’t accurately characterise the impact of the Bill.” In its response to the consultation on conversion therapy, the EHRC said that a ban should initially focus on attempts to change sexual orientation, while a ban on “conversion therapy attempting to change a person to or from being transgender should follow, once more detailed and evidence-based proposals are available”. A clause to allow “informed consent” to conversion therapy in the Conversion Therapy (Prohibition) Bill has been condemned by activists but was not criticised in the EHRC’s response. LGBTQ+ charity Stonewall said the EHRC’s response disregarded the expert opinion on of the UN Independent Expert on Sexual Orientation and Gender Identity and violated the ‘Paris Principles’ of promoting and protecting human rights as a UN-accredited National Human Rights Institution.
The Joint Committee on Human Rights has launched its investigation into proposals to reform the Human Rights Act. The Committee will examine government proposals to replace the Human Rights Act with a “Bill of Rights”, which would reduce the impact that case law from European Court of Human Rights has on domestic law.
In the courts:
Pwr (Appellant) v Director of Public Prosecutions (Respondent) and Akdogan and another (Appellants) v Director of Public Prosecutions (Respondent) [2022] – this case concerned section 13(1) of the Terrorism Act 2000, which makes it a criminal offence for a person to display an article in public, in a way that arouses “reasonable suspicion that he is a member or supporter of a proscribed organisation”. The appellants had carried flags of the Kurdistan Workers Party (the PKK), a proscribed organisation, at a demonstration. The Supreme Court dismissed their appeals, finding that section 13(1) is: a) a strict liability offence, such that there is no necessary mental element beyond the defendant knowing they are displaying the relevant article; and (b) compatible with article 10 of the European Convention of Human Rights (ECHR). Section 13(1)’s interference with the Article 10 right to freedom of expression is justified by being prescribed by law; in pursuit of legitimate aims; and necessary in a democratic society and proportionate to its legitimate aims.
R (Binder, Eveleigh, Hon and Paulley) v Secretary of State for Work and Pensions [2022] EWHC 105 (Admin) – the High Court allowed a judicial review claim by four disabled adults and granted a declaration that the government’s National Disability Strategy is unlawful. While there was no common law or statutory duty on the defendants to consult before publishing the Strategy, the Court held that their “UK Disability Survey” amounted to a voluntary consultation (which the defendant denied), and as such the common law principles of consultation fairness (“the Gunning principles”) applied. The Survey breached the second Gunning principle to “enable intelligent consideration and response” due to its lack of information (it did not outline or allow for comments on specific policy proposals), and format (the questions were all multiple choice except four open-ended questions with word-limits). The Court rejected the Claimants’ additional submission that the defendant breached the Public Sector Equality Duty per section 149 of the Equality Act 2010.
R (D4) (Notice of Deprivation of Citizenship) v Secretary of State for the Home Department [2022] EWCA Civ 33 – ‘D4’ was a British and Pakistani dual citizen who has been detained at a camp in Syria for three years. On 27 December 2019 she was deprived of her British citizenship under Regulation 10(4) of the British Nationality (General) Regulations 2003, which permits the Home Secretary to “serve notice” of a deprivation of British citizenship merely by putting the notice on a person’s Home Office file. On 28 September her solicitors requested the Foreign Office’s assistance in repatriating and it was then that the deprivation of her citizenship was first communicated to either D4 or her advisors. This case was a judicial review of Regulation 10(4) and the Court of Appeal found the regulation ultra vires; it went beyond the Home Secretary’s powers under the British Nationality Act 1981 and was therefore unlawful. However, if the Nationality and Borders Bill is passed, it will remove the requirement to give notice if it is “in the public interest” and will apply to this case retrospectively, effectively making lawful D4’s deprivation of citizenship without personal notice. (see last week’s round-up for more on deprivation of citizenship)
On the UKHRB:
Nicola Barker looks at the Independent Human Rights Act Review and the proposed Bill of Rights
Sapan Maini-Thompson asks whether “perception-based recording” of hate crimes is compatible with freedom of speech
The Appellant, Harry Miller, succeeded in this appeal. Image: The Guardian
In R (Harry Miller) v The College of Policing [2021] EWCA Civ 1926, the Court of Appeal ruled that current police guidance on the recording of ‘hate incidents’ unlawfully interferes with the right to freedom of expression. The decision overturns a 2020 ruling by the High Court in which Mr Miller’s challenge to the lawfulness of the Hate Crime Operational Guidance was dismissed (discussed previously on this Blog here).
Facts
The central issue raised in the appeal is the lawfulness of certain parts of the Hate Crime Operational Guidance. The Guidance, issued in 2014 by the College of Policing, sets out the national policy in relation to the monitoring and recording of what are described as “non-crime hate incidents”. At the root of the challenge is the policy of “perception-based recording”, which states that non-crime hate incidents must be recorded by the police as such (against the named person allegedly responsible) if the incident is subjectively perceived by the “victim or any other person to be motivated by a hostility or prejudice against a person who is transgender or perceived to be transgender” and irrespective of any evidence of the “hate” element.
Mr Miller, who is described as having “gender critical” beliefs, was reported to Humberside Police by Mrs B in January 2019 for posting comments on his Twitter account, which she asserted were “designed to cause deep offence and show his hatred for the transgender community.” Whilst there was no evidence of a criminal offence, the incident was recorded as a “hate incident” and Mr Miller was visited at work by a police officer who told him to “check his thinking.” Mr Miller subsequently brought a claim for judicial review.
Do they have anything in common? Relatively little, says Nicola Barker, Professor of Law at the University of Liverpool.
When the IHRAR was announced by Robert Buckland in December 2020, it was accompanied by some of the usual rhetoric about the courts “rewriting” legislation, but the more hyperbolic claims about foreign criminals and pet cats were absent. The Terms of Reference given to the IHRAR were relatively narrow and the Call for Evidence emphasised that it was ‘not considering the substantive rights set out in the Convention’. Instead, the Review was to focus only the operation of the HRA under two themes: the relationship between domestic courts and the ECtHR; and the impact of the HRA on the relationship between the three branches of the state.
However, in its consultation document, the government’s language once again carries echoes of the pet cat oeuvre with a stance premised on the idea of a ‘broader public interest’ that must be ‘safeguarded’ (para 182) from the HRA. In this, they are articulating a problem that lies not so much with the HRA’s impact on the separation of powers and Parliamentary sovereignty (though those remain too) but with ‘the way in which [Convention] rights have been applied in practice’ (para 184). In other words, the focus is back on how to prevent rights from benefitting the ‘undeserving’ and how to forestall further development of rights through the ‘living tree’ doctrine.
Given that the Review was only commissioned a year ago it is unfortunate to see several reforms proposed in the government’s consultation that could have usefully been included within the remit of the Review but were omitted from the Terms of Reference, not least the proposals in relation to section 6. The government propose to expand the exception in section 6(2)(b) (that applies where a public authority was giving effect to primary legislation that could not be read or given effect in a way that is compatible with Convention rights) to include circumstances where the public authority is giving effect to the clear intentions of Parliament (para 274). This proposal is based on the premise that section 6 has created ‘confusion and risk aversion for frontline public services’ (para 132-140) and undermined public protection as the police and armed forces ‘find operational decisions challenged’ and ‘have a court retrospectively second-guess their professional judgement exercised under considerable pressure’ (para 142). It is regrettable that the Review was not able to consider the accuracy of the premise underlying such potentially far-reaching reforms, which could significantly undermine individual rights protection in the UK.
The more substantive questions of the balance between speech and privacy, between rights and responsibilities, limiting access to Convention rights in the context of deportation, and whether a specific right to jury trial is necessary, could also have been usefully informed by the extensive research, in-depth discussion with a variety of stakeholders, and objective analysis that were characteristic of the Review.
The table below maps the government’s proposals for a new Bill of Rights on to the recommended and not recommended/rejected options in the IHRAR report. The government makes around 40 proposals, though some present alternative options rather than separate and distinct proposals. Green text indicates where the government’s proposals broadly match a recommendation of the IHRAR, while red text indicates that the government are proposing something that the Review explicitly or implicitly cautioned against. Sometimes the proposals do not map in exactly the terms recommended or rejected by the Review, but I have matched them as closely as possible with the language used by each. For example, where the government proposals refer to ‘enabling’ UK courts to take account of case law from other jurisdictions and international bodies (a power they already can and do exercise), the Review did not consider affirming this existing power but rejected ‘requiring’ them to consider such case law. As the table illustrates, the government’s proposals bear little resemblance to the recommendations made by the IHRAR panel. More of the government’s proposals are ideas that were rejected by the Review than were recommended by it and around half of the government’s proposals were not considered by the Review at all, in most cases because they were outside of its Terms of Reference.
The Independent Review recommended first, and in my view most importantly, that there should be more public education about the UK constitution and HRA in schools, universities, and adult education. The Review itself could form the basis of that education. It is a thorough and clear exposition of the Act, its interpretation and use by the Courts, and its impact on the separation of powers, Parliamentary sovereignty, and the relationship between the UK and Strasbourg. However, the government appears to have ignored this recommendation and in general the Review appears to have asserted little influence on the government’s proposals.
On Friday, the Guardian reported on the earlier Freemovement.org quantitative analysis relating to deprivations of British citizenship. While it has been known and reported upon for some time, the analysis demonstrates a continued trend of increased deprivations, with a significant peak in 2017, when the number of people whose citizenship was removed soared by 600%.
Protected by Article 15 of the 1948 Universal Declaration of Human Rights following the Second World War, the right to a nationality was described by Hannah Arendt as the very ‘right to have rights’. Nationality underpins individuals’ belonging to states, which can be the only true guarantors of individual self-governance through the medium of inalienable rights.
Prior to 2006, the power to remove citizenship had not been used since 1973. Now, strengthened by the Immigration, Asylum and Nationality Act 2006, which allowed the UK government to order deprivation of citizenship against its citizens where it believes it is ‘conducive to the public good’, 175 people have had their citizenship removed on national security grounds, and 286 due to fraud (even though the latter power relating to fraud was already enshrined in s.40 of the British Nationality Act 1981). The additional power to render individuals stateless was introduced by the Immigration Act 2014, under which the Secretary of State may remove citizenship where she has reasonable grounds for believing that the person deprived ‘is able’ to become a national of another country. This was most visibly achieved in the case of Shamima Begum, considered extensively on the UK Human Rights Blog.
The Court of Appeal dismissed a set of claims for psychiatric injury on the basis of prior binding authority, but indicated that the issue is suitable for consideration by the Supreme Court.
Background
The judgment concerns three linked appeals regarding the circumstances in which relative(s) of somebody injured or killed by alleged clinical negligence (the secondary victim(s)) can claim damages in respect of a psychiatric disorder caused by having witnessed the death or suffering of their loved one (the primary victim).
For a defendant to be liable for a secondary victim’s psychiatric illness, the claimant needs to show the necessary legal proximity between themselves and the defendant. In Alcock v Chief Constable of the South Yorkshire Police [1992] 1 AC 310, Lord Oliver identified five elements which form the essential requirements of such a relationship:
the secondary victim is in a marital/parental relationship with the primary victim;
the psychiatric illness for which damages are claimed arises from a sudden and unexpected shock to the secondary victim’s nervous system;
the secondary victim was personally present at the scene of the accident or was in more or less the immediate vicinity and witnessed the aftermath shortly afterwards;
the psychiatric illness arose from witnessing the death of, extreme danger to, or injury and discomfort suffered by the primary victim; and
there was not only an element of physical proximity to the event but a close temporal connection between the event and the secondary victim’s perception of it.
These elements were applied in Crystal Taylor v A. Novo (UK) Ltd [2013] EWCA Civ 194. The secondary victim claim of a daughter who witnessed her mother’s death three weeks after an accident at work in which negligently stacked racking boards fell on her failed despite her death having been caused by the accident. The Court of Appeal held that as she was not present at the accident, she lacked the necessary legal proximity.
Barry Bennell was a football coach who sexually abused a number of boys in the 1980s. He is serving a sentence of 34 years imprisonment and, at the age of 68, is likely to die in jail. The Claimants in this case were his victims. Mr Justice Johnson described each as a ‘remarkable’ men, courageously giving evidence and some waiving their rights to anonymity determined to do everything they could to encourage others to come forward and ensure Bennell was prosecuted and, ultimately, convicted.
The issue in this case was not the veracity of their account – the judge made is explicitly clear they were believed and the Defendant did not question the fact the abuse had occurred. The dispute was whether civil liability attached to Manchester City football club for the abuse committed by Bennell. There were two fundamental hurdles for the Claimants: limitation and vicarious liability. On the particular facts, the court found that they failed to overcome both.
The pandemic has had a knock-on effect of increasing awareness of devolution. The governments of Northern Ireland, Scotland and Wales have been responsible for navigating the pandemic in their own countries, and the approaches taken have sometimes significantly diverged. With the COVID Regulations affecting the essentials of our daily lives, public attention across the UK has been drawn to the powers of devolved governments to govern differently from Westminster.
One surprising difference between the Welsh and UK Governments – and one that has evaded much public scrutiny – is that the Welsh Regulations created a new power of entry which allows police officers to enter people’s homes in certain circumstances to investigate breaches of the COVID Regulations. No such power has ever been included in the English Regulations, and the power of English police officers to enter people’s homes is more restricted, governed by the provisions of the Police and Criminal Evidence Act 1984 (‘PACE’) and the common law rules for dealing with breaches of the peace.
The practical issues around the Welsh police power of entry to people’s homes have fallen into the background in recent months, because it mainly arises when there is or has been a suspected unlawful gathering in someone’s home. (Although on 26 December 2021, a new restriction was introduced banning gatherings of more than 30 in homes.) With restrictions hopefully easing again, reflecting on this regulation raises broader questions about human rights and legal scrutiny in Wales.
In a judgment handed down on 24 November 2021, the Court of Appeal dismissed an appeal concerning the lawfulness of the Self-Employment Income Support Scheme (“the Scheme”) which was introduced by the Government in April 2020 during the first lockdown as part of its response to the Covid-19 pandemic.
Background
The purpose of the Scheme was to provide payments for persons carrying on a trade where their business had been adversely affected by the pandemic. The payments were to be calculated by reference to the average trading profits (“ATP”) of the preceding full tax years (2016/17, 2017/18, 2018/2019).
The First Appellant, Motherhood Plan, also known as “Pregnant Then Screwed”, is a registered charity with aims to end discrimination faced by women and mothers by campaigning to change legislation, raising awareness in the media and working with employers to change business practice and culture. The Second Appellant, Ms Kerry Chamberlain, worked as a self-employed energy analyst. In the tax year 2017-18, she took a 39-week period of maternity leave after the birth of her second child, and, in the following tax year, she took a further 39-week period of leave after the birth of her third child. As a result of her periods away from work, her trading profits were reduced.
They claimed that contrary to Article 14 of the European Convention on Human Rights (“the Convention”), read with Article 1 of the First Protocol of the Convention, the Scheme unlawfully discriminated against self-employed women who took a period of leave relating to maternity or pregnancy in any of those three preceding full tax years since the level of support granted to them under the Scheme was not representative of their usual profits.
Mark Zuckerberg’s Meta platform is under pressure from the UK’s data watchdog, the Information Commissioner’s Office (ICO), over reports that their latest virtual reality headset, the ‘Oculus Quest 2’, does not have adequate parental controls, exposing children to harmful content. The ICO said it will investigate whether it violates the so-called ‘Children’s Code’, a set of regulations introduced in the UK four months ago which seeks to protect children online. The campaign group, Centre of Countering Digital Hate (CCDH), conducted research on the device, finding frequent instances of inappropriate behaviour on the app often used by Oculus Quest 2 players, VRChat. This included two ‘heavily breathing’ men following a child’s avatar, and another man joking that he was ‘a convicted sex offender’. If Meta has breached the code, it could be fined up to £2.5bn. However, it is unclear whether the device will be found to have breached the Code even if insufficient parental controls are in place, given that the regulations largely focus on the misuse of data, rather than the content children are exposed to on apps.
In our latest episode I and co-presenter Emma-Louise Fenelon have selected and put together some of our favourite snippets from the past year. This episode ranges from Artificial Intelligence, the government’s abandon with Henry VIII powers, to vicarious trauma in lawyers dealing with traumatic casework and the Henrietta Lacks claim against a pharmaceutical company for profiting from her cell lines in 1951.
This selection is by no means comprehensive and we’ve had to leave many deserving episodes out in the interests of brevity. For those wanting to keep abreast of their CPD requirements or just after a good informative listen, go back to some of our episodes on Medical and Inquest Law, Loss of Chance in clinical negligence, and “Historical” Crimes: Ireland’s unmarried mothers and their children.
We have been building on our impressive audience figures around the world, with listeners in over twenty countries including the United States, New Zealand, Spain, Saudi Arabia and Taiwan. In the summer of 2021 we passed the half a million listeners mark.
As we settle into the new year we have plenty of interesting names and topics in the pipeline for you. Law Pod UK is one of the longest running legal podcasts from barristers’ chambers in the UK and we have commanded sufficient authority and respect to gain access to big names, such as the founder of the Magnitsky Act, Bill Browder, and former chief prosecutor for England and Wales Nazir Afzal OBE.
The Colston Four have been acquitted of criminal damage by a jury for their role in pulling down the statue of Edward Colston in Bristol and pushing it into Bristol Harbour during a Black Lives Matter protest in June 2020. Under the Criminal Damage Act 1971, a defendant will have a defence to criminal damage if they can prove they had a ‘lawful excuse’ for their actions. In this case, the four defendants put forward three lawful excuses. First, they argued that they had been acting to prevent the crime of public indecency which was being committed in the retention of the statue after 30 years of petitions to remove it, given the serious offence and distress it caused. Relatedly, they contended that Bristol County Council had committed misconduct in failing to take it down, but this was withdrawn from the jury by HHJ Peter Blair QC as there was insufficient evidence. Second, they argued that they genuinely believed the statue was the property of Bristol citizens, and that those citizens would consent to the statue being pulled down. Finally, they contended that a conviction would be a disproportionate interference with their rights under Articles 10 and 11 of the European Convention on Human Rights (to freedom of expression and assembly). The verdict has been criticised by some as a politically motivated decision which has no proper basis in law, and a petition to retry the protesters has received over 13,000 signatures. Supporters of the Colston four maintain on the other hand that their excuses have a real foundation in the law, and that therefore it had been open to the jury to find the defendants not guilty.
The approach of juries in protest cases has come under further scrutiny in light of the new proposal in the Police Crime, Sentencing, and Courts Bill to increase the maximum sentence for the damage of memorials to 10 years imprisonment, irrespective of the cost of the damage. The increase in sentence means that all cases would necessarily be tried by a jury, which some legal commentators have suggested makes it more likely that perpetrators will go free.
Nine of the Hooded Men. Photo by Cyril Byrne/The Irish Times
In one of its final decisions of 2021, McQuillan, McGuigan and McKenna, the UK Supreme Court addressed challenges to the effectiveness of police investigations into events which took place during the Northern Ireland conflict. The European Court has long maintained that the right to life (Article 2 ECHR) and the prohibition upon torture and inhuman and degrading treatment (Article 3 ECHR) carry with them positive obligations on the state to conduct effective investigations. These “legacy” cases not only draw the Courts into debates over some of the most contentious aspects of the Northern Ireland conflict, in particular the involvement of state agents in killings and the infliction of serious harms upon individuals, but they also pose questions about how human rights law applied in the context of Northern Ireland as a jurisdiction before the enactment of the Human Rights Act 1998.
The decisions
For reasons of economy, this post will focus on the facts of the McGuigan and McKenna elements of this litigation, which concerned the ill-treatment of detainees who had been interned in the 1970s (while also exploring broader questions which concerned all elements in the litigation). The scope of this ill-treatment, involving the subjection of internees to the infamous “five techniques” (including hooding of detainees to disorient) as part of interrogations, has long been known. Indeed, the resultant case of Ireland v United Kingdom remains a key turning point in the development of the European Convention on Human Rights, demonstrating that the Strasbourg Court would be willing to uphold human rights claims against an important member state even as it sought to tackle political violence. In that decision, although the Court found that the five techniques breached Article 3 ECHR, it discussed them in terms of inhuman and degrading treatment and not torture. Releases of documents by the National Archives (highlighted in a 2014 RTÉ documentary), however, showed UK Cabinet Ministers discussing the extent of the interrogation practices when they were taking place, and led to calls for fresh police investigations into whether there has been a coverup.
The European Court of Human Rights has, by a majority, declared the application inadmissible. The decision is final.
Background facts and law
The case concerned the refusal by a Christian-run bakery to make a cake with the words “Support Gay Marriage” and the QueerSpace logo on it which the applicant had ordered and the proceedings that had followed. The following summary is based on the Court’s press release.
The applicant, Gareth Lee, is a British national who was born in 1969 and lives in Belfast. He is associated with QueerSpace, an organisation for the lesbian, gay, bisexual and transgender community in Northern Ireland.
Although same-sex marriage had been enacted in the rest of the UK in 2014, it was made legal in Northern Ireland only in 2020.
In 2014, Mr Lee ordered a cake for a gay activist event set to take place not long after the Northern Irish Assembly had narrowly rejected legalising same-sex marriage for the third time. He ordered it from Asher’s bakery. The cake was to have an image of Bert and Ernie (popular children’s television characters), the logo of QueerSpace, and the slogan “Support Gay Marriage”. He paid in advance.
‘A bleak, poorly staffed, highly charged and toxic environment.’ (Callum Tulley)
The Brook House inquiry has recently concluded its first phase of hearings which took place between November 23 and December 10, 2021 at the International Dispute Resolution Centre (IDRC). Brook House is an Immigration Removal Centre (IRC) beside Gatwick Airport, originally managed by the private security company G4S. The inquiry was set up to investigate the actions and circumstances surrounding the ‘mistreatment’ of male detainees at Brook House between April 1 to August 31 2017, and specifically, examining whether the treatment experienced was contrary to Article 3 ECHR (the right not to be subjected to torture, inhuman or degrading treatment). This followed the damning footage filmed by an undercover reporter in Brook House during the ‘relevant period’, and broadcast on the BBC Panorama Programme ‘Undercover: Britain’s Immigration Secrets’ which aired on September 4, 2017.
Background
Callum Tulley was employed by Brook House from January 2015 as a detention custody officer. In this role he witnessed the disturbing culture and conduct of employees there and raised these concerns by email to the BBC Panorama team in January 2016. After a 14– month period providing intelligence and completing specialist training, Tulley began to secretly film 109 hours of footage over a three-month period – the contents of which exposed the degrading treatment of detainees by employees.
Tanya Morahan had a history of paranoid schizophrenia and harmful cocaine use. From mid-May 2018 she was an inpatient at a rehabilitation unit operated by the Central & North West London NHS Foundation Trust. She was initially detained under s.3 of the Mental Health Act 1983 but on 25 June 2018 the section was rescinded. On 30 June 2018 Tanya left the unit but didn’t return until the next evening, 1 July. On the afternoon of 3 July 2018, again with her doctors’ agreement, she left the ward but didn’t return. The Trust asked the police to visit her. They visited on 4 July 2018 but she did not answer the door. She was ultimately found dead on 9 July 2018. [para 2].
Background
The Coroner opened an inquest and found that Article 2 was not engaged. The family brought judicial review proceedings, arguing that: (1) the circumstances of Tanya’s death fell within a class of cases which gave rise to an automatic duty to conduct a Middleton inquest; (2) alternatively, that such duty arose because there were arguable breaches of a substantive operational duty (the Osman duty) owed by the Trust to take steps to avert the real and immediate risk of Tanya’s death by accidental drug overdose, a risk which was or ought to have been known to the Trust. [para 3].
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